Mandatory occurrence reporting for higher-risk buildings: a property manager workflow

For an occupied higher-risk residential building in England, the principal accountable person (PAP) must run one mandatory occurrence reporting system for the building. It needs to let residents, accountable persons (APs) and other building users report concerns quickly. The relevant AP then assesses reports for the part of the building it is responsible for. A qualifying occurrence needs a notice to the Building Safety Regulator (BSR) as soon as possible, followed by a report within 10 calendar days of identification.

That clock makes the hand-off important. A repair ticket, resident complaint or contractor finding can contain the first evidence of a safety occurrence. If it sits in a general inbox while teams debate who owns it, the building may lose time needed to protect people, make a sound assessment and report accurately.

Check that the occupied-building rules apply

The in-occupation regime discussed here applies in England to a residential building with at least two residential units that is at least 18 metres high or has at least seven storeys. The BSR's accountable-person guidance explains that an AP is the organisation or individual that owns, or has a legal obligation to repair, any common parts. Each building has one PAP. A managing agent working under a service contract is not automatically an AP; the underlying ownership and repairing obligations decide accountability.

Record the PAP, every AP and the parts for which each is responsible. Then identify the property managers, facilities staff and contractors who operate the process on their behalf. Delegating intake or administration does not move the statutory duty. Where there are several APs, give the triage team a current responsibility map and an escalation route for reports that cross boundaries.

Know the reporting threshold

Mandatory occurrence reporting is not a route for every defect. In occupation, a safety occurrence is an incident or situation involving structural failure or the spread of fire in the building which, if not remedied, would be likely to put a significant number of people at risk of death or serious injury. BSR describes serious injury here as injury needing immediate hospital treatment or causing a permanent or irreversible disabling condition.

The BSR reporting guidance gives examples that may meet the threshold, including the discovery of structural defects affecting load bearing; failure of compartmentation materials; failure of sprinklers, risers or smoke-control systems; and fire doors or seals failing to limit fire spread. These are examples, not an automatic checklist. The responsible AP still needs to assess the facts and the potential consequence for that building.

Do not confuse remedial speed with the reporting test. BSR says a qualifying occurrence must still be reported if it is remedied immediately. Equally, a defect does not become a mandatory occurrence merely because it is urgent or expensive. Keep the emergency response and the threshold assessment moving together, with a competent person involved where the evidence needs technical judgement.

Use one intake, with a clear safety route

The PAP's system must be accessible to residents, APs and other building users. BSR suggests offering routes such as email, telephone, online and in person, and making the information easy to find in the building. The published policy should explain what to report, how to report it, how it will be handled, how a person can request an update, and how information will be collected and stored.

In practice, a separate form is not enough. Connect the MOR route to the channels people already use. Train the repairs desk, concierge, out-of-hours team and contractors to flag possible fire-spread or structural concerns. If a resident raises a concern through the building-safety complaints process and it meets the MOR threshold, the relevant AP must identify and report it. The concern should not need to be submitted a second time on the “right” form.

Ask for useful facts without making technical language a condition of acceptance: where and when the issue was seen, what happened, whether anyone is at immediate risk, and whether a photo or video is available. Offer alternative formats and language support where needed. The person receiving the report can clarify gaps; a resident should not have to diagnose a structural or fire-safety failure.

Run the report through a five-stage workflow

Give each record an identification time and an assessment owner. The report deadline runs from identification, so do not silently replace that time with the moment a senior manager opens the case. Record why the AP concluded that the threshold was met or not met, who made that decision and what evidence they used. If another AP has already reported the same occurrence, BSR says a duplicate is not required, but the AP should obtain a copy of the submitted report to support that decision.

A normal maintenance workflow can carry the repair, approvals and completion evidence, but it should not swallow the MOR record. Link the two cases. Our controlled maintenance workflow sets out the underlying approval and evidence trail; the MOR case adds the accountable person's threshold decision and the regulator-facing submissions.

Submit the notice before building the full report

The notice goes first and should be made as soon as possible after a safety occurrence is identified. According to the BSR submission service, it asks for the building registration reference, contact details, the date and time of identification, a brief description and any immediate action taken to keep people safe. BSR then issues a reference for the fuller report.

The report is due within 10 calendar days of identification. It asks what happened or could happen, how the occurrence was found, its cause, who is affected, the action already taken, planned safety measures and supporting material. If more information will follow, BSR says to explain when it is expected. Waiting for a perfect investigation file is not a reason to miss the statutory sequence.

Build a deadline view that counts calendar days, not working days. It should show the person responsible, notice status, BSR reference, report due date, outstanding evidence and latest action. Escalate early enough for weekends and absences. The operational dashboard can help people act, but the AP must retain control of the legal assessment and the accuracy of what is submitted.

Keep the reporting record with the building evidence

The Higher-Risk Buildings (Management of Safety Risks etc) (England) Regulations 2023 require one system for the building, timely assessment, reporting within the required periods, accessibility and regular review. Keep the original report, triage notes, technical advice, immediate controls, notice, BSR reference, full report and later correspondence together. The safety occurrence should also be reflected in the building's safety case report.

Preserve the version and source of each item. A live case log should show who changed a decision and when, without overwriting the earlier record. Limit access to personal or sensitive material, while making the operational facts available to the people who need to assess and control the risk.

Review the system, not just individual cases

The PAP must review the MOR system regularly so it remains effective. Use completed cases, near misses and false starts to test whether reports reached the right AP quickly, whether residents could use the channels, whether out-of-hours escalation worked, and whether the notice and report deadlines were visible. Record the resulting change to the policy, training or responsibility map.

Include residents when setting up the system and consider consulting them when it changes. A technically complete policy that people cannot find or understand is a weak control. The wider landlord compliance checklist can help separate this building-level duty from tenancy and property compliance, while the HMO licensing guide covers a different regime that may apply to some accommodation. Neither replaces the higher-risk-building test.

For multi-building operations, see Tekniti's enterprise workflow approach. Give every building an accessible intake, named AP ownership, a recorded threshold decision, two visible reporting milestones and evidence that stays with the building. Software can route and track the work. Accountable people still make the judgement and submit accurate information.